In this edition of the Weekly Compliance Digest, we provide an update on OSHA’s rule on electric power generation, transmission and distribution installations. Enforcement of the rule’s provisions on revised minimum approach distances have been delayed until January 31, 2017.
Electric Power Generation, Transmission, and Distribution; Electrical Protective Equipment
What is it?
On April 11, 2014, OSHA issued a final rule revising the standards for the construction, operation and maintenance of electric power generation, transmission, and distribution lines and equipment.
The final rule revised the construction standard to make it more consistent with the general industry standard and made some revisions to both the construction and general industry requirements. The final rule included new or revised provisions on host employers and contractors, training, job briefings, fall protection, insulation and working position of employees working on or near live parts, minimum approach distances, protection from electric arcs, de-energizing transmission and distribution lines and equipment, protective grounding, operating mechanical equipment near overhead power lines, and working in manholes and vaults.
The final rule also revised the general industry and construction standards for electrical protective equipment. The new standard for electrical protective equipment, which matches the corresponding general industry standard, applied to all construction work and replaced the incorporation of out-of-date consensus standards.
Who is affected?
The final rule affected about 211,000 employees across approximately 24,400 establishments and 6,500 companies primarily in the following industries:
- Electric Power Transmission, Control, and Distribution
- Electric Power Generation
- Power and Communication Transmission Line Construction
- Electrical Contractors
- Industrial Power Generators
- Ornamental Shrub and Tree Services
- Major Publicly Owned Utilities
- Industrial Non-Building Structure Construction
- Water, Sewer, and Pipeline Construction
- Structural Steel Contractors
- Building Equipment and Other Machine Installation Contractors
What are the requirements?
The main requirements from the rule included:
- General training:
- Degree of training determined by risk to the worker for the hazard involved.
- Training for qualified workers to recognize and control or avoid electrical hazards present at the worksite.
- Training for line-clearance tree trimmers.
- Host and contract employers sharing information with each other on safety-related matters and coordination of work rules and procedures.
- Use of fall protection by qualified workers.
- Protection from flames and electric arc hazards:
- Employers must assess the workplace to identify workers exposed to flame or electric arc hazards.
- Employers must estimate the incident heat energy of any electric-arc hazard to which a worker would be exposed.
- Employers generally must provide workers exposed to hazards from electric arcs with protective clothing and other protective equipment.
- Multiple crews working together on the same lines or equipment must either: (a) coordinate their activities under a single worker in charge and work as if all of the employees formed a single crew; or (b) independently comply with the standard and, if there is no system operator in charge of the lines or equipment, have separate tags and coordinate de-energizing and re-energizing the lines and equipment with the other crews.
- Special precautions when employees perform work that could cause a cable to fail.
- Application of the Electrical Protective Equipment for Construction standard to all construction work, not just electrical power generation, transmission, and distribution work.
- Use of protective footwear as a supplementary form of protection.
What is next?
The final rule became effective on July 10, 2014, but certain provisions had compliance deadlines of January 1, 2015 or April 1, 2015.
One of those provisions was the final rule’s revised minimum approach distances for voltages of 5.1 kilovolts or greater, which had a compliance date of April 1, 2015. The revised provisions include a new requirement for employers to determine maximum anticipated per-unit transient overvoltages through an engineering analysis or, as an alternative, assume certain maximum anticipated per-unit transient overvoltages.
Following legal challenges, OSHA agreed in February 2015 to issue no citations regarding minimum approach distance requirements for voltages of 72.6 to 169 kilovolts, and 169.1 kilovolts and more, until January 31, 2016. However, recently OSHA extended again the compliance deadline, from January 31, 2016 to January 31, 2017. In addition, if peer-reviewed guidance regarding the calculation of maximum transient overvoltages is not available before May 1, 2016, OSHA says it will extend the enforcement date even further to give employers time to read and implement such guidance when it becomes available.
Visit Enablon Insights again next Friday for a brand new Weekly Compliance Digest!